The #loancharge was designed to be penal in order to force people into voluntary settlement. But HMRC got carried away with their settlement terms adding IHT & penal interest. They could only do so because the #loancharge was so penal. So challenge this “fair share” claim by HMRC 
This was the purpose of the #loancharge. It was meant to make the option of ‘voluntary’ settlement seem so much more attractive in comparison. Nobody was actually meant to suffer the #loancharge. But then the IHT department of HMRC decided that they too wanted their bit of flesh.
The #loancharge was never meant to be “fair” & neither now are the settlement terms. The irony of asking for IHT is that it’s due precisely because HMRC argue that it’s a write-off of a legitimate loan to the trust. (The attached was written by HMRC)
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